Final Submitted Comments On Fdeir For BNSF Scig Project 3 6 2012

Professor
VIA EMAIL
March 6, 2013
Mr. Christopher Cannon

Director of Environmental Management
Port of Los Angeles
425 South Palos Verdes Street
San Pedro, CA 90731
Re: Final Environmental Impact Report: Southern California International Gateway (SCIG)
Dear Mr. Cannon:
The Community Outreach and Engagement Program of the Southern California Environmental
Health Sciences Center based at Keck School of Medicine of USC submits the following
comments on the Port’s responses to comments included in the Final EIR (FEIR) in this matter.
Although we thank POLA staff for entering new information into the FEIR about the
carcinogencity of diesel exhaust and the fact that ultrafine particles are toxic and are not covered
by current standards (as had been previously claimed), we consider unresponsive many other
POLA responses to my comments on the DEIR and RDEIR.
Four of my concerns about the FEIR are:
1) Proximity to traffic related air pollution and its health impacts on children and
adults is ignored in DEIR, RDEIR and FEIR
In all of our previous comment letters and oral testimony, we have requested that the Port
describe and consider the large body of evidence showing that children who live near busy
roads, freeways or other sources of traffic pollution are more likely to develop lung function
problems and asthma, and that adults also suffer health effects from living or working near
traffic pollution. USC and UCLA investigators have published dozens of such studies, and the
USC studies include children living in Long Beach, CA. Despite our request that these studies
and the body of evidence be described in the EIR, they are not.
University of Southern California • 2001 N Soto Street, M/C 9237 • Los Angeles, CA 90089-9237 • Tel: (323) 442-3077 • Fax: (323) 442-3272
Professor
2) The baseline used by the POLA for the “project” completely underestimates future
emissions and air pollution impacts from the Hobart Yard.
As many commenters have noted, the claimed “removal of trucks from the I-710” that would
have gone to Hobart Yard if SCIG is built provides a reduction in air pollution in the project’s
CEQA baseline. But the future emissions from Hobart as more and more transloading occurs
and as Hobart fills up are not considered in the “purview” of the EIRWe cite here the South
Coast AQMD comments on the DEIR which appropriately challenge the methods used by
POLA to develop its CEQA baseline with regard to Hobart Yard.
The AQMD wrote: “In short, much of the DEIR (including its health impacts and needed
mitigations) is based on a fundamental but unsubstantiated assumption that constructing SCIG
will eliminate truck trips to Hobart. But nothing in the SCIG project approval would limit
capacity at Hobart, and BNSF has stated no intention to reduce operations there. There is a
direct tie between building SCIG and opening up capacity at Hobart, and the EIR must analyze
how much of that capacity will be filled, e.g. by domestic freight. Only then can a valid
assessment of truck and locomotive traffic and emissions impacts of SCIG be developed. The
EIR is fundamentally deficient under CEQA without a thorough analysis of this issue.”
{SCAQMD letter with comments on DEIR dated February 2, 2012 to Chris Cannon, POLA}.
3) The public was refused access to the detailed explanation of the complex 52 pages
of Excel sheets in Appendix G4 during the period of comment for the RDEIR – and
was denied access to a report by the consulting firm that produced Appendix G4
In all of my previous comment letters, I have discussed the failure of the Port to develop
accurate statistics on transloading. In the RDEIR, suddenly 52 pages of Excel sheets appeared,
produced by Cambridge Systematics (CS). Since there was no accompanying section in the
FEIR about the methodology used by CS to produce the Excel sheets – in fact, the RDEIR did
not even a legend for the dozens of abbreviations used, I requested a report by CS report dated
August 2012 on transloading that was cited in the references. During the period of time when
comments were open for the RDEIR, this commenter did not receive the CS report, which the
Port actually claimed did not exist, nor did she receive the legend for abbreviations or any other
information about CS’s methodology in developing the 52 pages of Excel sheets. The Port
allowed a phone call with Gill Hicks of CS to help the commenter understand one of the tables
in the document.
As a result, no member of the public had any information about the CS calculations and CS
methodology or CS abbreviations until the FEIR was released in February 2013, at which time
Professor
four full pages of explanation about Appendix G4 was added. It was too late for the public to
analyze the Appendix or otherwise have any input.
I called Cambridge Systematics directly to see if I could get a copy of the consulting firm’s
August 2012 report that Chris Cannon said did not exist. The person said that the report could
only be released by the Ports – but that CS’s understanding was that the Ports were not planning
to “make the report public.”
4) It is unconscionable to claim that the impact of twice as many locomotives to be

serviced at the Sheila Yard in Commerce, CA is not an impact of the BNSF SCIG
Project, when the locomotives to be serviced would be arriving at the Sheila Yard
from the BNSF SCIG.
This is yet another example of the faulty analyses and assumptions in the entire BNSF SCIG
FEIR.
Please see my oral comments at the FDEIR hearing of March 7, 2013, attached, and attached
documentation provided. The refusal of the POLA to provide this information on such a
controversial project during an active comment period resulted in a great disservice to the
public.
Thank you for considering my comments.
Sincerely,
Andrea Hricko, MPH

Professor of Clinical Preventive Medicine
Keck School of Medicine
University of Southern California
Director, Community Outreach and Education Program
Southern California Environmental Health Sciences Center
2001 N. Soto Street, MC 9237
Los Angeles, CA 90089
Phone: 323-442-3077
Andrea Hricko, USC. ahricko@usc.edu, Comments on the FEIR for the BNSF SCIG Project
I work with the scientists at USC who conduct the Children’s Health Study. For the past 6 years, I and
others have submitted for the record USC and UCLA research findings showing that children who live or
go to school near traffic pollution are more likely to have lung function deficits and develop asthma. I
have repeatedly asked for a discussion of these research findings in the draft EIR and its revised
versions, all to no avail. If this project is built, there will be children and youth playing at schoolyards
several hundred feet from the rail yard, yet there is no discussion of the hundreds of papers
documenting what the proximity to traffic pollution may do to their health. None of the environmental
documents produced by the POLA even mention the words “lung function” – even though reduced lung
function is one of USC’s key findings in a study that includes hundreds of children from Long Beach
schools.
Meanwhile, for 6 years, both the Port and BNSF have consistently claimed that the SCIG project would
take more than a million trucks off the I‐710 that otherwise would have gone to the Hobart Yard in
Commerce, arguing that building the SCIG will somehow reduce air pollution. In February 2005, before
the environmental review even started, then‐Mayor Hahn proclaimed that the SCIG would eliminate one
million truck trips a year, without even doing any calculations!
The rhetoric has not changed in 6 years. But during that time there have been major new industry
trends. By 2011, industry journals did major stories about “transloading,” in which the imported goods
inside three 40‐foot ocean‐going containers are transferred into two 53‐foot containers, which big‐box
retailers have grown to prefer. Much of this transferring of goods occurs between the Ports and the
Commerce rail yards, and it and involves trucks traveling on the I‐710 to get to the rail yards. The trend
is so popular that trade journals report that 25‐30% of all the imported containers coming in the Ports of
LA and Long Beach are handled this way. But the Port ignored all those statistics in its draft EIR in 2011,
claiming a figure of only 8%. (DEIR at 1‐21).
Why does any of this matter? Because BNSF claims that only 40‐foot containers will be handled at SCIG.
But the more transloading there is, the more 53‐foot containers there are that need to get onto rail.
BNSF can send those 53‐foot containers to Hobart, which, BNSF says will expand even if the SCIG is built.
The Port says that Hobart’s expansion is “beyond the purview of the SCIG RDEIR.” That’s right,
thousands more trucks on the I‐710 carrying 53‐foot containers heading north to Hobart after SCIG is
built – but it is beyond the purview for evaluating SCIG’s impacts.
14 days after the draft EIR for the SCIG was released, and 6 years after the NOP, the Port commissioned
a new study of transloading. In its work order, the Port refers to studies showing that transloading of
imported containers from the Ports is at 29% ‐‐ three times higher than it admitted in the DEIR. When
the newly commissioned report by Cambridge Systematics came out, it also concluded that 27% of
loaded import containers are now transloaded to rail. Despite these new statistics, the revised EIR and
the Final EIR all still claim that the SCIG will take more than a million trucks off that I‐710 Freeway.
When the revised revised EIR came out in September 2012, many of us had a hard time understanding
Appendix G4, a complex set of 52 pages of Excel sheets with calculations by Cambridge Systematics.
There was no explanation, no methodogy was provided and abbreviations on the Excel sheets had no
legend. I asked Chris Cannon for a copy of the CS August 2012 report, since it was cited as a reference in
the DEIR. He said there was no report, that CS had only produced charts and Tables for the revised EIR.
I asked again, explaining that I needed the actual report dated August 2012 to understand the Appendix.
He agreed to let Gill Hicks answer a few questions for me, but I never received either a legend for the
critical abbreviations nor the requested report before the revised DEIR comment period ended.
After the comment period was over, someone else sent me the “non‐existent” August 2012 report. It is
about 60‐pages long. Learning that I had the report in hand, Chris apologized for any so‐called
“miscommunication” that might have caused confusion with me or the public.
The report details how the Ports embrace transloading, why major big box retailers like it, how the
practice is on the rise. It even suggests that the Ports allow the SCIG to accept transloaded containers
and urges building more transload centers between the 110 and 710 Freeways. None of that language,
which raises some very interesting questions about air pollution, traffic and health, is in the final EIR.
The final EIR, which is now out, contains the first PUBLIC explanation for the abbreviations in the critical
Appendix charts, a full 5 months after I requested them.
Besides raising questions of trust, what this means is that no one had the Cambridge Systematics report
to review before comments were due on the RDEIR. I wonder, are there other important reports like
this one sitting on the Port’s shelves, out of public sight?
We need to be able to trust what the Port says, to have it be transparent in its calculations on truck trips
and air pollution, rather than putting obstacles in the public’s way that reduce understanding of
complex subjects. And we need a Port that recognizes the latest research findings on air pollution and
children’s health – on that acts to protect those who are vulnerable.
Thank you.

Environmental Review Chronology
for BNSF SCIG Project

September 20, 2005. NOP released.
September 23, 2011. DEIR released.
February 1, 2012. Comments due on DEIR.
September 27, 2012. RDEIR released.
November 13, 2012. Comments due on RDEIR.
February 22, 2013. FDEIR published.
March 7, 2013. Harbor Commissioners consider the
FEIR.

Attachments to Andrea Hricko’s oral comments on the
FDEIR for the BNSF SCIG Project

Andrea Hricko, USC, ahricko@usc.edu

Emails are in chronological order.
Requests are for a copy of the Cambridge Systematics (CS) transload
report commissioned by the Ports. Having the report and an
explanation of Appendix G4’s methodology and legend of
abbreviations was critical to understanding the complicated Excel
sheets created by CS for the BNSF SCIG Project’s RDEIR.

CS Report came out in August 2012.
Cited as August 2012 Report with that date in the RDEIR.
Slightly revised report came out in December 2012.
No versions received from POLA until February 2013 –
after comments were due on the RDEIR.
Andrea Hricko
From: Cannon, Chris [CCannon@portla.org]
Sent: Friday, October 05, 2012 4:38 PM
To: 'Andrea Hricko'
Subject: RE: Cambridge Systematics report
Okay, so I’ve looked into the reference you refer to. The reference ‐ Cambridge Systematics, Inc. (CS) and Starboard
Alliance LLC 2012 Transloading of Marine Containers in Southern California. August 2012 – should have been a
reference to data. CS prepared a couple of Chapter 1 tables, Tables 1‐2 and 1‐5, which cite “Transload data from
Cambridge Systematics and Starboard Alliance (2012).” That is the correct reference.

Regarding your detailed follow up questions, consistent with our public CEQA process, we provide everyone with the
same EIR, appendices and references and can really only answer limited basic questions before the end of the comment
period. If we offered individual explanation sessions for one person, we would have to do it for everyone. Your
questions would require technical explanations that go beyond what we can do. Instead, you are welcome to raise them
in a comment letter. When public comments are received we will respond to them and post the responses in the Final
EIR for everyone to see.

Sorry I can’t be of any further help.

Christopher Cannon
Environmental Management Division
Port of Los Angeles
San Pedro, CA 90731
310‐732‐3763 ph
310‐547‐4643 fx

From: Andrea Hricko [mailto:ahricko@usc.edu]
Sent: Friday, October 05, 2012 1:18 PM
To: Cannon, Chris
Subject: Cambridge Systematics report

Dear Chris: I am having a very hard time understanding part of the RDEIR. Having the Cambridge Systematics report is
critical to any understanding of page 1‐24 of the RDEIR. That page’s footnotes say that Transload to Rail (eastbound) is
estimated at 27% of loaded imports. THEN the table uses ½ that figure (13.5%). WHY??? The 27% figure is nearly
identical to the percentage that John Doherty at ACTA claims are currently transloaded import containers. That is, of all
containers coming into the ports, 27% are transloaded to rail.

On page 1‐9, the RDEIR uses the figure of 13.5% transloaded now and 16% transloaded by 2016.

On page 1‐22, the 27% figure is again given for transloaded import containers to rail.

These discrepancies make the RDEIR impossible to understand with regard to what will happen at Hobart. I hope that
you can send the CS report asap, in hopes it clears this up. It should have been on the disk, but I cannot find it. Andrea

Andrea M. Hricko
Prof of Prev Med
Keck School of Med, USC &
Director, Community Outreach and Education
Southern CA Env Health Sciences Ctr
2001 N. Soto Street, MC 9237, Los Angeles, CA
1
Andrea Hricko
From: Gill Hicks [GHicks@camsys.com]
Sent: Monday, October 15, 2012 9:58 AM
To: Andrea Hricko
Subject: Re: question re your report in the RDEIR of the BNSF SCIG
Hello Andrea:
Thanks for your inquiry. The POLA has asked me to respond as follows:
“We are unable to respond to questions outside of the CEQA process. Please submit a public comment letter to:
Chris Cannon, Director of Environmental Management

Port of Los Angeles
San Pedro, CA 90731
Or via email to: ceqacomments@portla.org
Thank you for your cooperation.”

Gill
Gill V. Hicks
Director, Southern California Operations
Cambridge Systematics, Inc.
445 S. Figueroa Street
Suite 2600
Main Office Phone: 213-612-7755
Direct Line: 213-612-7756
Fax: 213-612-7758
Cell: 310-403-6274
From: "Andrea Hricko" <ahricko@usc.edu>

To: <ghicks@camsys.com>
Cc: "'Andrea Hricko'" <ahricko@hsc.usc.edu>
Date: 10/12/2012 08:37 PM
Subject: question re your report in the RDEIR of the BNSF SCIG
Dear Mr. Hicks:

I hope you can answer a couple of simple technical questions about the Cambridge Systematics work in the BNSF SCIG RDEIR.

1.) On page 1‐22 of the RDEIR, a footnotes states that transload to rail (eastbound) is 27% of loaded imports. This figure is what
John Doherty of ACTA cites and also what you cite in several recent presentations. Questions: What does “eastbound” mean in that
footnote? My understanding is that at this point in time 27% of imported containers, those that come INTO the Ports, are
subsequently transloaded to RAIL. (not direction mentioned). Second, why is that figure “halved” in the table, where it says that
13.5% of the imported containers are transloaded? Can you explain that to me?

1

2). Something seems to be incorrect with the headings in Appendix G4. Both the 8.5 x 11 inch sheets and the 11 x 17 inch sheets
say that they are “TEU” numbers. But the numbers on the longer sheets are 1.85 times higher than the shorter sheets, meaning that
one of the sets is containers and the other is TEUs. Can you advise which is which?

3. Many thanks for your help in making the work of Cambridge Systematics more understandable. Best wishes, Andrea Hricko, USC

Andrea M. Hricko
Prof of Prev Med
Zip: 90089 for regular mail
Zip: 90032 for FedEx -- and for map directions to our location
Phone: 323-442-3077

2
Andrea Hricko
From: Andrea Hricko [ahricko@usc.edu]
To: 'Gill Hicks'
Cc: 'Cannon, Chris'
Subject: RE: question re your report in the RDEIR of the BNSF SCIG
Dear Gill: Thank you for your response. I assume you understand how impossible it is to understand an Appendix with
Excel sheets that have conflicting units in their headlines, no legends, and no accompanying text to explain what the
sheets mean. Of course, Cambridge Systematics should never have submitted a document like that to POLA, and of
course, POLA should never have included it in the REDIR without an explanation, legends and correct units. As a result,
including Appendix G4 in the RDEIR without the above is a disservice to the public; the Port’s refusal to explain Appendix
G4 is even worse. Transparency is what the CEQA process is supposed to be about.

Tx. A.

Andrea M. Hricko
Prof of Prev Med
Phone: 323-442-3077

From: Gill Hicks [mailto:GHicks@camsys.com]
To: Andrea Hricko
Subject: Re: question re your report in the RDEIR of the BNSF SCIG
Hello Andrea:
Thanks for your inquiry. The POLA has asked me to respond as follows:
“We are unable to respond to questions outside of the CEQA process. Please submit a public comment letter to:
Chris Cannon, Director of Environmental Management

Port of Los Angeles
San Pedro, CA 90731
Or via email to: ceqacomments@portla.org
Thank you for your cooperation.”

Gill
Gill V. Hicks
Director, Southern California Operations
Cambridge Systematics, Inc.
445 S. Figueroa Street
Suite 2600
1
Andrea Hricko
Sent: Friday, February 22, 2013 9:30 AM
To: Andrea Hricko; Knatz, Geraldine; kcartwright@portla.orgP
Subject: RE: Pls provide the August 2012 Cambridge Systematics Report
Attachments: CambridgeTransloadingEstimates2012.pdf
Good morning Andrea,
The August 2012 reference you have requested is attached. As you may recall, and as I pointed out to David, the August
2012 reference is not a report. It was data that was used to develop Appendix G4. At that time, the full report had not
been completed. The full report was finalized in December 2012 and you now have that too, which confirms the August
2012 data.
Feel free to give me a call if you have any questions.
Christopher Cannon
Port of Los Angeles
San Pedro, CA 90731
310-732-3763 Dir
310-547-4643 Fax

Sent: Thursday, February 21, 2013 10:20 PM
To: Knatz, Geraldine; Cannon, Chris; kcartwright@portla.orgP
Subject: Pls provide the August 2012 Cambridge Systematics Report
Dear Geraldine, Chris and Kerry: Thank you for sending David Pettit the December 2012 CS transloading report. Please
send me asap the August 2012 CS transloading report requested last week. Thank you. Andrea Hricko, USC

Andrea M. Hricko
Prof of Prev Med

Phone: 323-442-3077

-----------------------------------Confidentiality Notice--------------------------------------------------
This electronic message transmission contains information from the Port of Los Angeles, which may be confidential. If you
are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this information
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1
TO: Amnon Bar-Ilan THIS IS THE ATTACHMENT THAT CHRIS CANNON TOLD ME WAS THE AUGUST 2012 REPORT
FROM: Gill Hicks
SUBJECT: Transloading estimates
DATE: August 20, 2012
John Isbell of Starboard Alliance LLC has developed the following estimates of transloading in Southern
California. This table is part of the draft report on transloading.
Estimated Annual Import Rail and Truck Transload Volume in Southern California, FY 2011
IMC Market Share
Percentage
Low of SPBP
IANA Data1 Percent High Percent Average Volume2
Number of 53-Foot Domestic Rail Containers 641,696 702,703 619,048 654,482
Equivalent Number of TEU by Rail 1,926,069 2,109,184 1,857,948 1,964,400 27%
Equivalent Number of TEU by Truck 911,749 911,749 911,749 911,749 13%
Total Transload Volume 2,837,818 3,020,933 2,769,697 2,876,149 40%
153-foot container volume from July 2010 to June 2011 for Pacific Southwest adjusted for import products from Southern
California per TTX formula (80 percent originate in California; of that total 90 percent originate in Southern California; of which
90 percent are import products).
2SPBP Import TEU Volume July 2010 to June 2011 7,255,285 TEUs

Andrea Hricko
Sent: Sunday, March 03, 2013 3:26 PM
To: 'Andrea Hricko'; 'kcartwright@portla.org'; 'gknatz@portla.org'; 'Sanfield, Phillip'
Cc: 'Cannon, Chris'; 'dgalaviz@portla.org'; 'Arley Baker'
Subject: RE: Request re Cambridge Systematics report
Dear Kerry: I have in hand a copy of the August 2012 Transload Report marked “FINAL” by these contractors, despite
ongoing claims by Chris Cannon that no August 2012 transload report exists. Please, I would like to have a copy of the
SCOPE OF WORK or other contractual agreements with the contractors listed below commissioning this report. What
did you ask them do DO for the Port of L.A. and Long Beach? You need to let me know if you will not respond to this
ongoing request unless I submit a CPRA request. I urgently need this information for the upcoming week’s hearing on
the BSNF SCIG DEIR. Thank you. Andrea Hricko

‐‐‐‐‐

Earlier message on 2/25/2013: Dear Kerry: hope this finds you well. I am wondering if you can please send me the
description of work that the Ports submitted to Cambridge Systematics and Starboard Alliance for the work that it
wanted these consulting firms to do with regard to their completion of the 2012 transload report. Presumably, the
consulting firms were paid under an existing 3-year contract from 2011, according to Harbor
Commission transcripts (http://www.portoflosangeles.org/Board/2011/May/05-19-
11_RegAgenda_Item6_Transmittal_2A.pdf).
I need this asap because it is relevant to my review of the FEIR for the BNSF SCIG. Many thanks.
Andrea

From: Andrea Hricko [mailto:ahricko@usc.edu]
Sent: Wednesday, February 27, 2013 8:21 PM
To: 'kcartwright@portla.org'; 'gknatz@portla.org'; 'Sanfield, Phillip'
Subject: Request re Cambridge Systematics report

Kerry, I know it is only one day after my request, but I need this information asap for comments on the FEIR on the BNSF
SCIG.

The Ports of LA and Long Beach commissioned a transload study by Cambridge Systematics and Starboard Alliance (CS),
and as I understand it, the report was commissioned by you (Kerry) and, I assume, under a 2010 approved services
agreement with POLA, as authorized by the POLA Harbor Commissioners.

Please send me the scope of work that you requested from these contractors. Thank you. Andrea
1
Andrea Hricko
Sent: Monday, March 04, 2013 5:50 PM
To: 'Andrea Hricko'; Cartwright, Kerry; Knatz, Geraldine; Sanfield, Phillip
Cc: dgalaviz@portla.org; Baker, Arley; Crose, Joy; Sidley, Janna
Subject: RE: Request re Cambridge Systematics report
Attachments: POLA Transload Isbell Project Scope Statement.pdf; SCIG-Environ-Cambridge
Subcontract.pdf; POLA Directive #1_Amendment_Fully Executed 043012.pdf; POLA
Transload Integrated Scope of Work 120511.pdf
Hi Andrea,

I am responding to your email request for documents because Kerry is not in the office today. I have attached a series
of documents that hopefully respond to your email request for Scope of Work for the the Transloading Report that was
done as a joint port project for the ports of LA and Long Beach:

(1) A short summary of the scope of work for Cambridge/Starboard Alliance for development of the Transloading
Report,
(2) A longer more detailed version of the scope of work for Cambridge/Starboard for the same work
(3) The Port of Los Angeles Project Directive providing a notice to proceed for development of the Transloading
Report.

At the same time that Cambridge and Starboard were preparing the Transloading Report, Cambridge was under contract
with the Port of Los Angeles to provide support in development of the transportation analyses for the SCIG EIR. I have
also included the subcontractor agreement between ENVIRON and Cambridge for performance of that SCIG EIR work.
As you know, Cambridge’s work was used to develop Appendix G4 of the Recirculated Draft SCIG EIR, which was
released in September 2012.

Finally, it appears that I have provided some confusing communications to you regarding the Cambridge work. Please
excuse me for that. Cambridge and Starboard prepared a final draft of their Transloading Report for both ports review
in August. The document shouldn’t have had the words “final” on it, as it was submitted for comments. POLA staff did
have a few questions and input for the consultants and the final report was not completed until the publication of the
Final Report in December 2012. However, we just learned last week, that POLB actually released the report to a third
party when they saw the word “final” written on it. We were not aware of this. When POLA received your request in
October for copies of the Transloading Report, POLA responded that it was not yet a final report for release,** which was
an accurate statement as to POLA. Cambridge at that time was still revising the document. After POLA received the
Final Report in December, it was cited in the Final EIR and is available to the public. **POLA told Hricko there was no report.

POLA does not usually release draft documents that are superseded by final versions. Typically, we just release final
documents to avoid confusion. In this case, if POLA staff had known that POLB had released the August draft, it would
have made that version available as well but with the explanation that it was a draft. The draft and final versions of the
report are very similar and the findings do not materially change. We apologize for any confusion this may have caused
you or the public. ** Not having the report and the methodolgy/legends for App. G4 made it impossible for the public
to appropriately respond to that critical part of the RDEIR. The methodology and legend of abbreviations was supplied
5 months later, in the FDEIR (response from Andrea Hricko).

Feel free to call me if you have any questions.

Christopher Cannon
Port of Los Angeles
425 S. Palos Verdes Street
1
San Pedro, CA 90731

RESPONDING TO ANDREA HRICKO’S REQUEST FOR AN EXPLANATION OF
APPENDIX G4 (see next page for one page of Appendix G4 as it appeared in the RDEIR)
Hricko made the request of Chris Cannon in October 2012, saying that Appendix G4 was
incomprehensible without an explanation. Chris Cannon had Gill Hicks answer a few questions,
but Hricko never received any text, any report, or any list of abbreviations, nor an explanation of
the methodology used to create Appendix G4.
FEIR came out in February 2013 (five months later) with FOUR PAGES of explanation about
methodology and the abbreviations, none of which were available to the public during the comment period.
Here is an example of one paragraph from the 5-page introduction that was added to the
FEIR to help readers understand Appendix G4.:
The starting point for the analysis was to estimate 2010 baseline volumes by railyard and
market. These results are shown under Scenario 1 (Baseline 2010) in the following table.
Volumes in TEUs are shown for IPI containers (loads and empties), transloaded (TL)
containers (loads only), and pure domestic (DOM) containers and trailers (loads and
empties).
In the table, these three market segments are designated with the following
column headings, respectively: “IPI L + E”, “TL L”, and “Dom L + E”. Total TEUs are
also shown in the table and they are the sum of the values for the three separate markets.
There is no evidence that there is any westbound (or exported) transload volumes from
rail to marine container. The transload volumes shown in the table are all eastbound
loads (imports). These 53-foot containers return either as empties or as westbound
domestic cargo loads. Those volumes are counted in the Dom L + E column. IPI, direct
intermodal volumes in lifts are updated annually by the railroads and provided to the
ports, as well as total lifts at railyards. The analysis assumed that 27% of loaded imports
through the ports are transloaded to rail (Cambridge, 2013), and therefore the pure
domestic volumes were estimated as the difference between the (IPI + transloaded) lifts,
and the total lifts.
Marine containers loaded or unloaded on-dock are shown in the “IPI L +E” column only,
since on-dock yards do not handle transloaded or pure domestic containers. The tables
show volumes in both lifts and TEUs, marked as “Demand in Lifts” and “Demand in
TEUs.”
SEE NEXT PAGE FOR AN EXAMPLE OF WHAT APPENDIX G4 LOOKED LIKE IN THE RDEIR. THERE WAS
NO METHODOLOGY, NO LEGEND, NO EXPLANATION OF ABBREVIATIONS, ETC. AND POLA WOULD NOT
PROVIDE ANY OF THIS INFORMATION UNTIL FIVE MONTHS LATER WHEN THE FEIR CAME OUT. THIS
APPENDIX IS CRITICAL FOR THE PUBLIC TO UNDERSTAND THE CLAIMS MADE ABOUT THE BNSF SCIG PROJECT
TAKING TRUCKS OFF THE I-710 FREEWAY.
Transloading of San Pedro Ports Containerized Imports and Exports:
Integrated Scope of Work
December 4, 2011 (first two pages only)
Table of Contents
Problem Statement/Purpose of Study
Step 1: Literature review and evaluation of existing secondary data.
Step 2: Surveys of beneficial cargo owners, logistics service providers, and

intermodal marketing companies.
Step 3: Surveys of ocean carriers.
Step 4: Spreadsheet estimates of the current and future volume of transloading and
related trip tables.
Step 5: Draft and final reports
Attachment A: Scope of Work for Starboard Alliance LCC
Attachment B: Scope of Work for Global Business Advocates LLC
Attachment C: Proposed Budget
Attachment D: Summary of TTX Transload Study, 2011
1
Transloading of San Pedro Ports Containerized Imports and Exports:
Integrated Scope of Work
December 4, 2011
Problem Statement/Purpose of Study
The transloading of containerized imports from 40-foot ISO 1 marine containers to 53-
foot domestic containers or trailers is an important yet poorly understood component of
the international logistics market in Southern California. There is considerable
uncertainty about the exact volume of transloading, but recent estimates suggest that
nearly 30% of all loaded imports, or about 2 million TEUs in 2010, were transloaded to
53-foot containers for later movement by rail out of the region. 2 Transloading is
contrasted with “intact” rail shipments which involve the movement of marine boxes by
rail without any deconsolidation of the cargo. A smaller number of export shipments
(currently not estimated) involve transloading from 53-foot containers or trailers to 40-
foot marine containers.
Why do shippers transload? Transloading can help reduce shipping costs, depending on
the differential rates of moving containers in 40-foot and 53-foot containers. A rough
rule of thumb is that the cargo in three 40-foot high-cube marine containers can fit into
two 53-foot domestic containers. 3 Transloading also plays an important role in inventory
management. Cargo can be stored in local warehouses and then shipped later as the
market dictates. This helps the shipper manage seasonal or unexpected variations in
demand and also allows for “value added” services to be done at the warehouse, such as
labeling, adding price tags, placing clothing on hangars, etc.
Transloading has important implications for transportation planning in the port

area and in the SCAG region as whole. The amount of transloading affects the
number of truck trips generated by the ports as well as by transload facilities and
rail yards. In evaluating port-related land-side traffic it is important to identify
the constituent market segments that exhibit different travel patterns. Rail and
truck are the two basic markets, but they are inter-related and not mutually
exclusive categories.
The locations of the transload facilities in relation to the ports and the rail yards also
have important implications for trip generation, vehicle miles of travel, and emissions
(including greenhouse gas emissions.) Transloading involves “secondary trips”, i.e., the
trips from warehouses to rail yards in addition to the “primary trip” from the ports to
the warehouses. Most regional models have focused on the primary trips. New
1
International Standards Organization
2
TTX, Trade Flow Study, February 2011.
3
More precise conversion factors can be computed using actual interior capacities of different-sized
containers. www.nationalintermodal.com/equipment.htm.
2
Appendix G4: Intermodal Rail Analysis

Southern California International Gateway Recirculated Draft EIR September 2012

CONFIDENTIAL WORK PRODUCT: ATTORNEY CLIENT PRIVILEGE
SCIG DEIR Scenarios* TEUs & Trains Summary
IPI L+E IM Trains TL L IM Trains Dom L+E IM Trains Total IM Trains
No. Title Description SCIG ICTF Other rail Off-dock rail Transload Yard % Lifts IPI L+E TL L TEUs Dom L+E Total TEUs 12K 10K 8K 6K Total 12K 10K 8K 6K Total 12K 10K 8K 6K Total 12K 10K 8K 6K Total
included Imps projects (e.g., capacity permitted at Capacity TEUs TEUs
? included APL, Pier B, assumptions SCIG and ICTF? Utilization
? Pier S) *** (Domestic not
included? permitted at
ICTF and SCIG)
1 Baseline 2010 2010 conditions No No No 2010 conditions Small actual On-Dock Yards Total 3,312,578 3,312,578 0.0 6.6 8.8 6.6 22.1 0.0 6.6 8.8 6.6 22.1
volume at ICTF in On-Dock Yards BNSF Total 1,866,821 1,866,821 0.0 3.7 5.0 3.7 12.5 0.0 3.7 5.0 3.7 12.5
2010: 3,752 lifts On-Dock Yards UP Total 1,445,756 1,445,756 0.0 2.9 3.9 2.9 9.6 0.0 2.9 3.9 2.9 9.6
48+ foot containers
Off-Dock Yards Total 1,642,151 1,917,754 3,195,640 6,755,545 0.0 3.3 4.4 3.3 11.0 0.0 3.8 4.7 0.9 9.4 0.0 4.4 12.0 4.3 20.7 0.0 11.4 21.1 8.5 41.1
BNSF Off-Dock Yards Total 807,466 915,349 1,853,853 3,576,668 0.0 1.6 2.2 1.6 5.4 0.0 1.8 2.3 0.5 4.5 0.0 2.1 8.0 3.2 13.3 0.0 5.5 12.4 5.3 23.2
Hobart & Commerce Yards 56.9% 807,219 505,585 1,004,236 2,317,040 0.0 1.6 2.2 1.6 5.4 0.0 1.0 1.2 0.2 2.5 0.0 1.1 4.4 1.8 7.3 0.0 3.7 7.8 3.6 15.2
San Bernardino Yard 64.8% 247 409,764 849,617 1,259,628 0.0 0.0 0.0 0.0 0.0 0.0 0.8 1.0 0.2 2.0 0.0 1.0 3.6 1.4 6.0 0.0 1.8 4.6 1.6 8.0
SCIG Yard N/A 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Additional BNSF Yard Capacity Needed 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
UP Off-Dock Yards Total 834,685 1,002,405 1,341,787 3,178,877 0.0 1.7 2.2 1.7 5.6 0.0 2.0 2.5 0.5 4.9 0.0 2.3 4.0 1.1 7.4 0.0 6.0 8.7 3.3 17.9
East L.A. Yard 63.3% 66,352 440,252 676,923 1,183,527 0.0 0.1 0.2 0.1 0.4 0.0 0.9 1.1 0.2 2.2 0.0 1.2 2.0 0.5 3.7 0.0 2.2 3.3 0.9 6.3
ICTF Yard 51.3% 752,386 7,356 3,900 763,642 0.0 1.5 2.0 1.5 5.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 2.0 1.5 5.0
City of Industry Yard 99.7% 185 333,828 359,698 693,711 0.0 0.0 0.0 0.0 0.0 0.0 0.7 0.8 0.2 1.6 0.0 0.7 0.9 0.2 1.8 0.0 1.4 1.7 0.4 3.5
LATC Yard 54.1% 15,763 220,968 301,267 537,998 0.0 0.0 0.0 0.0 0.1 0.0 0.4 0.5 0.1 1.1 0.0 0.4 1.1 0.4 1.9 0.0 0.9 1.7 0.5 3.1
Additional UP Yard Capacity Needed 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Total Additional Yard Capacity Needed 0 0 0 0
Total including Additional Yard Capacity Needed 4,954,729 1,917,754 3,195,640 10,068,123 0.0 9.9 13.2 9.9 33.1 0.0 3.8 4.7 0.9 9.4 0.0 4.4 12.0 4.3 20.7 0.0 18.1 29.9 15.2 63.2
Total excluding Additional Yard Capacity Needed 4,954,729 1,917,754 3,195,640 10,068,123
2 Baseline 2010 2010 conditions Yes No No 2010 conditions Small actual On-Dock Yards Total 3,312,578 3,312,578 0.0 6.6 8.8 6.6 22.1 0.0 6.6 8.8 6.6 22.1
With Project with 2035 SCIG volume at ICTF in On-Dock Yards BNSF Total 1,866,821 1,866,821 0.0 3.7 5.0 3.7 12.5 0.0 3.7 5.0 3.7 12.5
considering only volumes.** 2010: 3,752 lifts On-Dock Yards UP Total 1,445,756 1,445,756 0.0 2.9 3.9 2.9 9.6 0.0 2.9 3.9 2.9 9.6
positive increases in 48+ foot containers
TEUs that take place BNSF Off-Dock Yards Total 2,921,053 915,349 1,853,853 5,690,255 0.0 0.3 16.6 0.0 16.8 0.0 1.8 2.3 0.5 4.5 0.0 2.1 8.0 3.2 13.3 0.0 4.1 26.8 3.6 34.6
entirely at BNSF Off-
Dock Yards
SCIG Yard 100.0% 2,775,000 0 0 2,775,000 0.0 0.0 16.0 0.0 16.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 16.0 0.0 16.0
East L.A. Yard 63.3% 66,352 440,252 676,923 1,183,527 0.0 0.1 0.2 0.1 0.4 0.0 0.9 1.1 0.2 2.2 0.0 1.2 2.0 0.5 3.7 0.0 2.2 3.3 0.9 6.3
ICTF Yard 51.3% 752,386 7,356 3,900 763,642 0.0 1.5 2.0 1.5 5.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 2.0 1.5 5.0
LATC Yard 54.1% 15,763 220,968 301,267 537,998 0.0 0.0 0.0 0.0 0.1 0.0 0.4 0.5 0.1 1.1 0.0 0.4 1.1 0.4 1.9 0.0 0.9 1.7 0.5 3.1
3 2016 No Project No Yes as POLA Modified Maximum No On-Dock Yards Total 5,866,291 5,866,291 0.0 11.0 22.3 0.0 33.3 0.0 11.0 22.3 0.0 33.3
assuming equal assumed in Practical On-Dock Yards BNSF Total 2,933,146 2,933,146 0.0 5.5 11.1 0.0 16.6 0.0 5.5 11.1 0.0 16.6
BNSF-UP IPI market deriving at Capacities at On-Dock Yards UP Total 2,933,146 2,933,146 0.0 5.5 11.1 0.0 16.6 0.0 5.5 11.1 0.0 16.6
shares demand for 2016 HOB&COM, ELA,
LATC and COI
Yards BNSF Off-Dock Yards Total 634,231 1,385,175 2,089,841 4,109,247 0.0 1.2 2.4 0.0 3.6 3.2 1.6 0.0 0.0 4.8 0.0 3.2 6.4 0.0 9.6 3.2 5.9 8.8 0.0 18.0
SCIG Yard N/A 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 37.9% 31,712 692,587 1,044,920 1,769,219 0.0 0.1 0.1 0.0 0.2 1.6 0.8 0.0 0.0 2.4 0.0 1.6 3.2 0.0 4.8 1.6 2.4 3.3 0.0 7.4
ICTF Yard 21.7% 602,520 0 0 602,520 0.0 1.1 2.3 0.0 3.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.1 2.3 0.0 3.4
LATC Yard 50.8% 0 554,070 835,936 1,390,006 0.0 0.0 0.0 0.0 0.0 1.3 0.6 0.0 0.0 1.9 0.0 1.3 2.6 0.0 3.8 1.3 1.9 2.6 0.0 5.8
4 2016 With Project 2016 Cumulative Yes Yes as POLA Modified Maximum No On-Dock Yards Total 5,866,291 5,866,291 0.0 11.0 22.3 0.0 33.3 0.0 11.0 22.3 0.0 33.3
assuming equal assumed in Practical On-Dock Yards BNSF Total 2,933,146 2,933,146 0.0 5.5 11.1 0.0 16.6 0.0 5.5 11.1 0.0 16.6
BNSF-UP IPI market deriving at Capacities at On-Dock Yards UP Total 2,933,146 2,933,146 0.0 5.5 11.1 0.0 16.6 0.0 5.5 11.1 0.0 16.6
shares demand for 2016 HOB&COM, ELA,
LATC and COI
SCIG Yard 21.7% 602,520 0 0 602,520 0.0 0.0 3.7 0.0 3.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.7 0.0 3.7
East L.A. Yard 37.9% 31,712 692,587 1,044,920 1,769,219 0.0 0.1 0.1 0.0 0.2 1.6 0.8 0.0 0.0 2.4 0.0 1.6 3.2 0.0 4.8 1.6 2.4 3.3 0.0 7.4
ICTF Yard 21.7% 602,520 0 0 602,520 0.0 1.1 2.3 0.0 3.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.1 2.3 0.0 3.4
LATC Yard 50.8% 0 554,070 835,936 1,390,006 0.0 0.0 0.0 0.0 0.0 1.3 0.6 0.0 0.0 1.9 0.0 1.3 2.6 0.0 3.8 1.3 1.9 2.6 0.0 5.8
Southern California International Gateway Recirculated Draft EIR G4-1 September 2012
ICTF and SCIG)
5 2023 No Project No Yes Yes Modified Maximum No On-Dock Yards Total 8,276,066 8,276,066 0.0 15.5 31.4 0.0 46.9 0.0 15.5 31.4 0.0 46.9
assuming equal Practical On-Dock Yards BNSF Total 4,138,033 4,138,033 0.0 7.7 15.7 0.0 23.5 0.0 7.7 15.7 0.0 23.5
BNSF-UP IPI market Capacities at On-Dock Yards UP Total 4,138,033 4,138,033 0.0 7.7 15.7 0.0 23.5 0.0 7.7 15.7 0.0 23.5
shares HOB&COM, ELA,
LATC and COI
Hobart & Commerce Yards 54.5% 897,330 1,376,342 1,946,231 4,219,904 0.0 1.7 3.4 0.0 5.1 3.2 1.6 0.0 0.0 4.8 0.0 2.9 6.0 0.0 8.9 3.2 6.2 9.4 0.0 18.8
SCIG Yard N/A 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 57.6% 44,867 983,101 1,390,165 2,418,133 0.0 0.1 0.2 0.0 0.3 2.3 1.1 0.0 0.0 3.4 0.0 2.1 4.3 0.0 6.4 2.3 3.3 4.4 0.0 10.0
ICTF Yard 30.7% 852,464 0 0 852,464 0.0 1.6 3.2 0.0 4.8 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.6 3.2 0.0 4.8
LATC Yard 68.7% 0 786,481 1,112,132 1,898,613 0.0 0.0 0.0 0.0 0.0 1.8 0.9 0.0 0.0 2.7 0.0 1.7 3.4 0.0 5.1 1.8 2.6 3.4 0.0 7.8
6 2023 With Project 2023 Cumulative Yes Yes Yes Modified Maximum No On-Dock Yards Total 8,276,066 8,276,066 0.0 15.5 31.4 0.0 46.9 0.0 15.5 31.4 0.0 46.9
LATC and COI
SCIG Yard 30.7% 852,464 0 0 852,464 0.0 0.0 5.2 0.0 5.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 5.2 0.0 5.2
East L.A. Yard 57.6% 44,867 983,101 1,390,165 2,418,133 0.0 0.1 0.2 0.0 0.3 2.3 1.1 0.0 0.0 3.4 0.0 2.1 4.3 0.0 6.4 2.3 3.3 4.4 0.0 10.0
ICTF Yard 30.7% 852,464 0 0 852,464 0.0 1.6 3.2 0.0 4.8 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.6 3.2 0.0 4.8
LATC Yard 68.7% 0 786,481 1,112,132 1,898,613 0.0 0.0 0.0 0.0 0.0 1.8 0.9 0.0 0.0 2.7 0.0 1.7 3.4 0.0 5.1 1.8 2.6 3.4 0.0 7.8
LATC and COI
Yards BNSF Off-Dock Yards Total 2,029,747 3,081,230 4,121,169 9,232,146 0.0 3.8 7.7 0.0 11.5 7.2 3.5 0.0 0.0 10.7 0.0 6.2 12.7 0.0 18.9 7.2 13.6 20.4 0.0 41.1
Hobart & Commerce Yards 96.1% 2,029,747 2,156,861 3,065,538 7,252,146 0.0 3.8 7.7 0.0 11.5 5.0 2.5 0.0 0.0 7.5 0.0 4.6 9.4 0.0 14.0 5.0 10.9 17.1 0.0 33.1
San Bernardino Yard 100.0% 0 924,369 1,055,631 1,980,000 0.0 0.0 0.0 0.0 0.0 2.2 1.1 0.0 0.0 3.2 0.0 1.6 3.2 0.0 4.8 2.2 2.7 3.2 0.0 8.1
SCIG Yard N/A 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
UP Off-Dock Yards Total 2,029,747 3,081,230 4,121,169 9,232,146 0.0 3.8 7.7 0.0 11.5 7.2 3.5 0.0 0.0 10.7 0.0 6.2 12.7 0.0 18.9 7.2 13.6 20.4 0.0 41.1
East L.A. Yard 100.0% 101,487 1,540,615 2,044,811 3,686,913 0.0 0.2 0.4 0.0 0.6 3.6 1.8 0.0 0.0 5.4 0.0 3.1 6.3 0.0 9.4 3.6 5.1 6.7 0.0 15.3
ICTF Yard 69.5% 1,928,260 0 0 1,928,260 0.0 3.6 7.3 0.0 10.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.6 7.3 0.0 10.9
LATC Yard 100.0% 0 1,232,492 1,467,508 2,700,000 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0
8a 2035 With Project 2035 Cumulative Yes Yes Yes Modified Maximum No On-Dock Yards Total 11,683,706 11,683,706 0.0 21.9 44.4 0.0 66.3 0.0 21.9 44.4 0.0 66.3
assuming projected Practical On-Dock Yards BNSF Total 5,841,853 5,841,853 0.0 10.9 22.2 0.0 33.1 0.0 10.9 22.2 0.0 33.1
IPI demand for SCIG Capacities at On-Dock Yards UP Total 5,841,853 5,841,853 0.0 10.9 22.2 0.0 33.1 0.0 10.9 22.2 0.0 33.1
and equal BNSF-UP HOB&COM, ELA,
LATC and COI
IPI market shares
SCIG Yard 69.5% 1,928,260 0 0 1,928,260 0.0 0.0 11.9 0.0 11.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 11.9 0.0 11.9
East L.A. Yard 100.0% 101,487 1,540,615 2,044,811 3,686,913 0.0 0.2 0.4 0.0 0.6 3.6 1.8 0.0 0.0 5.4 0.0 3.1 6.3 0.0 9.4 3.6 5.1 6.7 0.0 15.3
ICTF Yard 69.5% 1,928,260 0 0 1,928,260 0.0 3.6 7.3 0.0 10.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.6 7.3 0.0 10.9
LATC Yard 100.0% 0 1,232,492 1,467,508 2,700,000 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0
ICTF and SCIG)
8b 2035 With Project 2035 Cumulative Yes Yes Yes Modified Maximum No On-Dock Yards Total 11,683,706 11,683,706 0.0 21.9 44.4 0.0 66.3 0.0 21.9 44.4 0.0 66.3
assuming maximum Practical On-Dock Yards BNSF Total 5,841,853 5,841,853 0.0 10.9 22.2 0.0 33.1 0.0 10.9 22.2 0.0 33.1
demand equal to Capacities at On-Dock Yards UP Total 5,841,853 5,841,853 0.0 10.9 22.2 0.0 33.1 0.0 10.9 22.2 0.0 33.1
capacity of SCIG HOB&COM, ELA,
LATC and COI
giving BNSF higher BNSF Off-Dock Yards Total 2,921,053 3,081,230 4,121,169 10,123,452 0.0 0.3 16.6 0.0 16.8 7.2 3.5 0.0 0.0 10.7 0.0 6.2 12.7 0.0 18.9 7.2 10.0 29.2 0.0 46.4
IPI market share Yards
SCIG Yard 100.0% 2,775,000 0 0 2,775,000 0.0 0.0 16.0 0.0 16.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 16.0 0.0 16.0
East L.A. Yard 98.2% 56,922 1,540,615 2,117,079 3,714,616 0.0 0.1 0.2 0.0 0.3 3.6 1.8 0.0 0.0 5.4 0.0 3.2 6.5 0.0 9.7 3.6 5.1 6.7 0.0 15.4
ICTF Yard 39.0% 1,081,519 0 0 1,081,519 0.0 2.0 4.1 0.0 6.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.0 4.1 0.0 6.1
LATC Yard 100.0% 0 1,232,492 1,467,508 2,700,000 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0
LATC and COI
SCIG Yard N/A 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 100.0% 101,487 1,540,615 2,044,811 3,686,913 0.0 0.2 0.4 0.0 0.6 3.6 1.8 0.0 0.0 5.4 0.0 3.1 6.3 0.0 9.4 3.6 5.1 6.7 0.0 15.3
ICTF Yard 69.5% 1,928,260 0 0 1,928,260 0.0 3.6 7.3 0.0 10.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.6 7.3 0.0 10.9
City of Industry Yard 100.0% 0 308,123 852,366 1,160,489 0.0 0.0 0.0 0.0 0.0 0.7 0.4 0.0 0.0 1.1 0.0 1.3 2.6 0.0 3.9 0.7 1.6 2.6 0.0 5.0
LATC Yard 100.0% 0 1,232,492 1,467,508 2,700,000 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0
10a 2046 With Project 2046 Cumulative Yes Yes Yes Modified Maximum No On-Dock Yards Total 11,683,706 11,683,706 0.0 21.9 44.4 0.0 66.3 0.0 21.9 44.4 0.0 66.3
assuming projected Practical On-Dock Yards BNSF Total 5,841,853 5,841,853 0.0 10.9 22.2 0.0 33.1 0.0 10.9 22.2 0.0 33.1
IPI demand for SCIG Capacities at On-Dock Yards UP Total 5,841,853 5,841,853 0.0 10.9 22.2 0.0 33.1 0.0 10.9 22.2 0.0 33.1
and equal BNSF-UP HOB&COM, ELA,
LATC and COI
IPI market shares
SCIG Yard 69.5% 1,928,260 0 0 1,928,260 0.0 0.0 11.9 0.0 11.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 11.9 0.0 11.9
East L.A. Yard 100.0% 101,487 1,540,615 2,044,811 3,686,913 0.0 0.2 0.4 0.0 0.6 3.6 1.8 0.0 0.0 5.4 0.0 3.1 6.3 0.0 9.4 3.6 5.1 6.7 0.0 15.3
ICTF Yard 69.5% 1,928,260 0 0 1,928,260 0.0 3.6 7.3 0.0 10.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.6 7.3 0.0 10.9
LATC Yard 100.0% 0 1,232,492 1,467,508 2,700,000 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0
10b 2046 With Project 2046 Cumulative Yes Yes Yes Modified Maximum No On-Dock Yards Total 11,683,706 11,683,706 0.0 21.9 44.4 0.0 66.3 0.0 21.9 44.4 0.0 66.3
assuming maximum Practical On-Dock Yards BNSF Total 5,841,853 5,841,853 0.0 10.9 22.2 0.0 33.1 0.0 10.9 22.2 0.0 33.1
demand equal to Capacities at On-Dock Yards UP Total 5,841,853 5,841,853 0.0 10.9 22.2 0.0 33.1 0.0 10.9 22.2 0.0 33.1
capacity of SCIG HOB&COM, ELA,
LATC and COI
giving BNSF higher BNSF Off-Dock Yards Total 2,921,053 3,081,230 4,364,684 10,366,967 0.0 0.3 16.6 0.0 16.8 7.2 3.5 0.0 0.0 10.7 0.0 6.6 13.4 0.0 20.0 7.2 10.4 30.0 0.0 47.6
IPI market share Yards
SCIG Yard 100.0% 2,775,000 0 0 2,775,000 0.0 0.0 16.0 0.0 16.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 16.0 0.0 16.0
East L.A. Yard 100.0% 56,922 1,540,615 2,117,079 3,714,616 0.0 0.1 0.2 0.0 0.3 3.6 1.8 0.0 0.0 5.4 0.0 3.2 6.5 0.0 9.7 3.6 5.1 6.7 0.0 15.4
ICTF Yard 39.0% 1,081,519 0 0 1,081,519 0.0 2.0 4.1 0.0 6.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.0 4.1 0.0 6.1
LATC Yard 100.0% 0 1,232,492 1,467,508 2,700,000 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0
ICTF and SCIG)
LATC and COI
SCIG Yard N/A 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 57.3% 40,324 849,975 1,232,612 2,122,911 0.0 0.1 0.2 0.0 0.2 2.0 1.0 0.0 0.0 3.0 0.0 1.9 3.8 0.0 5.6 2.0 2.9 3.9 0.0 8.8
ICTF Yard 27.6% 766,159 0 0 766,159 0.0 1.4 2.9 0.0 4.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.4 2.9 0.0 4.3
LATC Yard 61.7% 0 679,980 986,089 1,666,069 0.0 0.0 0.0 0.0 0.0 1.6 0.8 0.0 0.0 2.4 0.0 1.5 3.0 0.0 4.5 1.6 2.3 3.0 0.0 6.9
LATC and COI
SCIG Yard 27.6% 766,159 0 0 766,159 0.0 0.0 4.7 0.0 4.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 4.7 0.0 4.7
East L.A. Yard 57.3% 40,324 849,975 1,232,612 2,122,911 0.0 0.1 0.2 0.0 0.2 2.0 1.0 0.0 0.0 3.0 0.0 1.9 3.8 0.0 5.6 2.0 2.9 3.9 0.0 8.8
ICTF Yard 27.6% 766,159 0 0 766,159 0.0 1.4 2.9 0.0 4.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.4 2.9 0.0 4.3
LATC Yard 61.7% 0 679,980 986,089 1,666,069 0.0 0.0 0.0 0.0 0.0 1.6 0.8 0.0 0.0 2.4 0.0 1.5 3.0 0.0 4.5 1.6 2.3 3.0 0.0 6.9
LATC and COI
SCIG Yard N/A 0 0 0 0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 87.8% 71,831 1,352,925 1,823,335 3,248,091 0.0 0.1 0.3 0.0 0.4 3.2 1.6 0.0 0.0 4.7 0.0 2.8 5.6 0.0 8.4 3.2 4.4 5.9 0.0 13.5
ICTF Yard 49.2% 1,364,796 0 0 1,364,796 0.0 2.6 5.2 0.0 7.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.6 5.2 0.0 7.7
LATC Yard 94.1% 0 1,082,340 1,458,668 2,541,008 0.0 0.0 0.0 0.0 0.0 2.5 1.2 0.0 0.0 3.8 0.0 2.2 4.5 0.0 6.7 2.5 3.4 4.5 0.0 10.5
LATC and COI
SCIG Yard 49.2% 1,364,796 0 0 1,364,796 0.0 0.0 8.4 0.0 8.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 8.4 0.0 8.4
East L.A. Yard 87.8% 71,831 1,352,925 1,823,335 3,248,091 0.0 0.1 0.3 0.0 0.4 3.2 1.6 0.0 0.0 4.7 0.0 2.8 5.6 0.0 8.4 3.2 4.4 5.9 0.0 13.5
ICTF Yard 49.2% 1,364,796 0 0 1,364,796 0.0 2.6 5.2 0.0 7.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.6 5.2 0.0 7.7
LATC Yard 94.1% 0 1,082,340 1,458,668 2,541,008 0.0 0.0 0.0 0.0 0.0 2.5 1.2 0.0 0.0 3.8 0.0 2.2 4.5 0.0 6.7 2.5 3.4 4.5 0.0 10.5
CONFIDENTIAL DATA: ATTORNEY CLIENT PRIVILEGE
SCIG Scenarios Lifts/TEUs Data from Train Builder Intermodal Rail Analysis Module embedded in Quick Trip - Train Builder Integrated Model
Prepared for the Port of Los Angeles by Cambridge Systematics on August 13, 2012
Scenario #1 - Baseline 2010

DEMAND in Lifts IPI L+E TL L Dom L+E Total Lifts Util. %
On-Dock Yards Total 1,840,321 1,840,321
% Market Split 100%
On-Dock Yards BNSF Total 1,037,123 1,037,123
On-Dock Yards UP Total 803,198 803,198
Off-Dock Yards Total 912,306 639,251 1,091,004 2,642,561

% Market Split 35% 24% 41%
BNSF Off-Dock Yards Total 448,592 305,116 640,338 1,394,046

Hobart & Commerce Yards 448,455 168,528 349,491 966,474 56.9%
San Bernardino Yard 137 136,588 290,847 427,572 64.8%
SCIG Yard 0 0 0 0
Additional BNSF Yard Capacity Needed 0 0 0 0
UP Off-Dock Yards Total 463,714 334,135 450,666 1,248,515

East L.A. Yard 36,862 146,751 227,856 411,469 63.3%
ICTF Yard 417,992 2,452 1,300 421,744 51.3%
City of Industry Yard 103 111,276 119,900 231,279 99.7%
LATC Yard 8,757 73,656 101,610 184,023 54.1%
Additional UP Yard Capacity Needed 0 0 0 0

Total including Additional Yard Capacity Needed 2,752,627 639,251 1,091,004 4,482,882
Total excluding Additional Yard Capacity Needed 2,752,627 639,251 1,091,004 4,482,882
CONFIDENTIAL DATA: ATTORNEY CLI
SCIG Scenarios Lifts/TEUs Data from Train Builder Intermodal Rai
Prepared for the Port of Los Angeles by Cambridge Systematics o
Scenario #2 - Baseline 2010 w. 2035 BNSF volumes

DEMAND in Lifts IPI L +E TL L Dom L+E Total Lifts Util. %
% Market Split 100%
On-Dock Yards UP Total 803,198 803,198
Off-Dock Yards Total 2,042,661 639,251 1,091,004 3,772,916

BNSF Off-Dock Yards Total 1,578,947 305,116 640,338 2,524,401

SCIG Yard 1,500,000 0 0 1,500,000 100.0%

East L.A. Yard 36,862 146,751 227,856 411,469 63.3%
ICTF Yard 417,992 2,452 1,300 421,744 51.3%
LATC Yard 8,757 73,656 101,610 184,023 54.1%

Scenario #3 - 2016 No Project

% Market Split 100%
On-Dock Yards UP Total 1,585,484 1,585,484


Hobart & Commerce Yards 342,828 323,207 487,630 1,153,665 38.5%
SCIG Yard 0 0 0 0 N/A

East L.A. Yard 17,141 230,862 348,307 596,311 47.7%
ICTF Yard 325,686 0 0 325,686 21.7%
LATC Yard 0 184,690 278,645 463,335 51.5%

Scenario #4 - 2016 w. Project

% Market Split 100%


SCIG Yard 325,686 0 0 325,686 21.7%

East L.A. Yard 17,141 230,862 348,307 596,311 47.7%
ICTF Yard 325,686 0 0 325,686 21.7%
LATC Yard 0 184,690 278,645 463,335 51.5%


% Market Split 100%
Off-Dock Yards Total 970,087 1,310,802 1,853,554 4,134,443



East L.A. Yard 24,252 327,700 463,388 815,341 65.2%
ICTF Yard 460,791 0 0 460,791 30.7%
LATC Yard 0 262,160 370,711 632,871 70.3%

Total including Additional Yard Capacity Needed 5,443,636 1,310,802 1,853,554 8,607,992

% Market Split 100%


SCIG Yard 460,791 0 0 460,791 30.7%

East L.A. Yard 24,252 327,700 463,388 815,341 65.2%
ICTF Yard 460,791 0 0 460,791 30.7%
LATC Yard 0 262,160 370,711 632,871 70.3%


% Market Split 100%
Off-Dock Yards Total 2,194,321 2,054,153 2,747,446 6,995,920

BNSF Off-Dock Yards Total 1,097,160 1,027,077 1,373,723 3,497,960

Hobart & Commerce Yards 1,097,160 718,954 1,021,846 2,837,960 94.6%
UP Off-Dock Yards Total 1,097,160 1,027,077 1,373,723 3,497,960

East L.A. Yard 54,858 513,538 681,604 1,250,000 100.0%
ICTF Yard 1,042,302 0 0 1,042,302 69.5%
LATC Yard 0 410,831 489,169 900,000 100.0%

Scenario #8a - 2035 w. Project (Equal BNSF-UP IPI Share)

% Market Split 100%


Hobart & Commerce Yards 54,858 718,954 1,021,846 1,795,658 59.9%
SCIG Yard 1,042,302 0 0 1,042,302 69.5%

East L.A. Yard 54,858 513,538 681,604 1,250,000 100.0%
ICTF Yard 1,042,302 0 0 1,042,302 69.5%
LATC Yard 0 410,831 489,169 900,000 100.0%

Scenario #8b - 2035 w. Project (BNSF Higher IPI Share)

% Market Split 100%


SCIG Yard 1,500,000 0 0 1,500,000 100.0%
UP Off-Dock Yards Total 615,374 1,027,077 1,373,723 3,016,173

East L.A. Yard 30,769 513,538 705,693 1,250,000 100.0%
ICTF Yard 584,605 0 0 584,605 39.0%
LATC Yard 0 410,831 489,169 900,000 100.0%


% Market Split 100%


Hobart & Commerce Yards 1,097,160 718,954 1,103,018 2,919,132 97.3%

East L.A. Yard 54,858 513,538 681,604 1,250,000 100.0%
ICTF Yard 1,042,302 0 0 1,042,302 69.5%
LATC Yard 0 410,831 489,169 900,000 100.0%


% Market Split 100%


SCIG Yard 1,042,302 0 0 1,042,302 69.5%

East L.A. Yard 54,858 513,538 681,604 1,250,000 100.0%
ICTF Yard 1,042,302 0 0 1,042,302 69.5%
LATC Yard 0 410,831 489,169 900,000 100.0%


% Market Split 100%


SCIG Yard 1,500,000 0 0 1,500,000 100.0%

East L.A. Yard 30,769 513,538 705,693 1,250,000 100.0%
ICTF Yard 584,605 0 0 584,605 39.0%
LATC Yard 0 410,831 489,169 900,000 100.0%


% Market Split 100%



East L.A. Yard 21,797 283,325 410,871 715,992 57.3%
ICTF Yard 414,140 0 0 414,140 27.6%
LATC Yard 0 226,660 328,696 555,356 61.7%


% Market Split 100%


SCIG Yard 414,140 0 0 414,140 27.6%

East L.A. Yard 21,797 283,325 410,871 715,992 57.3%
ICTF Yard 414,140 0 0 414,140 27.6%
LATC Yard 0 226,660 328,696 555,356 61.7%


% Market Split 100%

BNSF Off-Dock Yards Total 776,555 901,950 1,215,557 2,894,062

UP Off-Dock Yards Total 776,555 901,950 1,215,557 2,894,062

East L.A. Yard 38,828 450,975 607,778 1,097,581 87.8%
ICTF Yard 737,727 0 0 737,727 49.2%
LATC Yard 0 360,780 486,223 847,003 94.1%


% Market Split 100%


SCIG Yard 737,727 0 0 737,727 49.2%
UP Off-Dock Yards Total 776,555 901,950 1,215,557 2,894,062

East L.A. Yard 38,828 450,975 607,778 1,097,581 87.8%
ICTF Yard 737,727 0 0 737,727 49.2%
LATC Yard 0 360,780 486,223 847,003 94.1%

SCIG Scenarios Lifts/TEUs Data from Train Builder Intermodal Rail Analysis Module embedded in Quick Trip - Train Builder Integrated Model

DEMAND in TEUs IPI L+E TL L Dom L+E Total TEUs
% Market Split 100%


Hobart & Commerce Yards 807,219 505,585 1,004,236 2,317,040
San Bernardino Yard 247 409,764 849,617 1,259,628
SCIG Yard 0 0 0 0
Additional BNSF Yard TEUs to be handled 0 0 0 0

East L.A. Yard 66,352 440,252 676,923 1,183,527
ICTF Yard 752,386 7,356 3,900 763,642
City of Industry Yard 185 333,828 359,698 693,711
LATC Yard 15,763 220,968 301,267 537,998
Additional UP Yard TEUs to be handled 0 0 0 0

Scenario #2 - Baseline 2010 w. Project

DEMAND in TEUs IPI TL L Dom L+E Total TEUs
% Market Split 100%

BNSF Off-Dock Yards Total 2,921,053 915,349 1,853,853 5,690,255

SCIG Yard 2,775,000 0 0 2,775,000

East L.A. Yard 66,352 440,252 676,923 1,183,527
ICTF Yard 752,386 7,356 3,900 763,642
LATC Yard 15,763 220,968 301,267 537,998


% Market Split 100%

BNSF Off-Dock Yards Total 634,231 1,385,175 2,089,841 4,109,247

SCIG Yard 0 0 0 0

East L.A. Yard 31,712 692,587 1,044,920 1,769,219
ICTF Yard 602,520 0 0 602,520
LATC Yard 0 554,070 835,936 1,390,006


% Market Split 100%


SCIG Yard 602,520 0 0 602,520

East L.A. Yard 31,712 692,587 1,044,920 1,769,219
ICTF Yard 602,520 0 0 602,520
LATC Yard 0 554,070 835,936 1,390,006


% Market Split 100%


Hobart & Commerce Yards 897,330 1,376,342 1,946,231 4,219,904
SCIG Yard 0 0 0 0

East L.A. Yard 44,867 983,101 1,390,165 2,418,133
ICTF Yard 852,464 0 0 852,464
LATC Yard 0 786,481 1,112,132 1,898,613


% Market Split 100%


SCIG Yard 852,464 0 0 852,464

East L.A. Yard 44,867 983,101 1,390,165 2,418,133
ICTF Yard 852,464 0 0 852,464
LATC Yard 0 786,481 1,112,132 1,898,613


% Market Split 100%


Hobart & Commerce Yards 2,029,747 2,156,861 3,065,538 7,252,146
San Bernardino Yard 0 924,369 1,055,631 1,980,000
SCIG Yard 0 0 0 0

East L.A. Yard 101,487 1,540,615 2,044,811 3,686,913
ICTF Yard 1,928,260 0 0 1,928,260
LATC Yard 0 1,232,492 1,467,508 2,700,000


% Market Split 100%


SCIG Yard 1,928,260 0 0 1,928,260

East L.A. Yard 101,487 1,540,615 2,044,811 3,686,913
ICTF Yard 1,928,260 0 0 1,928,260
LATC Yard 0 1,232,492 1,467,508 2,700,000


% Market Split 100%


SCIG Yard 2,775,000 0 0 2,775,000

East L.A. Yard 56,922 1,540,615 2,117,079 3,714,616
ICTF Yard 1,081,519 0 0 1,081,519
LATC Yard 0 1,232,492 1,467,508 2,700,000


% Market Split 100%


SCIG Yard 0 0 0 0

East L.A. Yard 101,487 1,540,615 2,044,811 3,686,913
ICTF Yard 1,928,260 0 0 1,928,260
City of Industry Yard 0 308,123 852,366 1,160,489
LATC Yard 0 1,232,492 1,467,508 2,700,000


% Market Split 100%


SCIG Yard 1,928,260 0 0 1,928,260

East L.A. Yard 101,487 1,540,615 2,044,811 3,686,913
ICTF Yard 1,928,260 0 0 1,928,260
LATC Yard 0 1,232,492 1,467,508 2,700,000


% Market Split 100%


SCIG Yard 2,775,000 0 0 2,775,000

East L.A. Yard 56,922 1,540,615 2,117,079 3,714,616
ICTF Yard 1,081,519 0 0 1,081,519
LATC Yard 0 1,232,492 1,467,508 2,700,000


% Market Split 100%


SCIG Yard 0 0 0 0

East L.A. Yard 40,324 849,975 1,232,612 2,122,911
ICTF Yard 766,159 0 0 766,159
LATC Yard 0 679,980 986,089 1,666,069


% Market Split 100%


SCIG Yard 766,159 0 0 766,159

East L.A. Yard 40,324 849,975 1,232,612 2,122,911
ICTF Yard 766,159 0 0 766,159
LATC Yard 0 679,980 986,089 1,666,069


% Market Split 100%


SCIG Yard 0 0 0 0

East L.A. Yard 71,831 1,352,925 1,823,335 3,248,091
ICTF Yard 1,364,796 0 0 1,364,796
LATC Yard 0 1,082,340 1,458,668 2,541,008


% Market Split 100%


SCIG Yard 1,364,796 0 0 1,364,796

East L.A. Yard 71,831 1,352,925 1,823,335 3,248,091
ICTF Yard 1,364,796 0 0 1,364,796
LATC Yard 0 1,082,340 1,458,668 2,541,008

SCIG Scenarios Trains Data from Train Builder Intermodal Rail Analysis Module embedded in Quick Trip - Train Builder Integrated Model

IPI L+E TL L Dom L+E Total
IM Trains 12K 10K 8K 6K TOTAL 12K 10K 8K 6K TOTAL 12K 10K 8K 6K TOTAL 12K 10K 8K 6K TOTAL
On-Dock YardsTotal 0.0 6.6 8.8 6.6 22.1 0.0 6.6 8.8 6.6 22.1
On-Dock Yards BNSF Total 0.0 3.7 5.0 3.7 12.5 0.0 3.7 5.0 3.7 12.5
On-Dock Yards UP Total 0.0 2.9 3.9 2.9 9.6 0.0 2.9 3.9 2.9 9.6
Off-Dock Yards Total 0.0 3.3 4.4 3.3 11.0 0.0 3.8 4.7 0.9 9.4 0.0 4.4 12.0 4.3 20.7 0.0 11.4 21.1 8.5 41.1
BNSF Off-Dock Yards Total 0.0 1.6 2.2 1.6 5.4 0.0 1.8 2.3 0.5 4.5 0.0 2.1 8.0 3.2 13.3 0.0 5.5 12.4 5.3 23.2
Hobart & Commerce Yards 0.0 1.6 2.2 1.6 5.4 0.0 1.0 1.2 0.2 2.5 0.0 1.1 4.4 1.8 7.3 0.0 3.7 7.8 3.6 15.2
San Bernardino Yard 0.0 0.0 0.0 0.0 0.0 0.0 0.8 1.0 0.2 2.0 0.0 1.0 3.6 1.4 6.0 0.0 1.8 4.6 1.6 8.0
SCIG Yard 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Additional BNSF Yard Capacity Needed 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
UP Off-Dock Yards Total 0.0 1.7 2.2 1.7 5.6 0.0 2.0 2.5 0.5 4.9 0.0 2.3 4.0 1.1 7.4 0.0 6.0 8.7 3.3 17.9
East L.A. Yard 0.0 0.1 0.2 0.1 0.4 0.0 0.9 1.1 0.2 2.2 0.0 1.2 2.0 0.5 3.7 0.0 2.2 3.3 0.9 6.3
ICTF Yard 0.0 1.5 2.0 1.5 5.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 2.0 1.5 5.0
City of Industry Yard 0.0 0.0 0.0 0.0 0.0 0.0 0.7 0.8 0.2 1.6 0.0 0.7 0.9 0.2 1.8 0.0 1.4 1.7 0.4 3.5
LATC Yard 0.0 0.0 0.0 0.0 0.1 0.0 0.4 0.5 0.1 1.1 0.0 0.4 1.1 0.4 1.9 0.0 0.9 1.7 0.5 3.1
Additional UP Yard Capacity Needed 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
All Rail Yards Total 0.0 9.9 13.2 9.9 33.1 0.0 3.8 4.7 0.9 9.4 0.0 4.4 12.0 4.3 20.7 0.0 18.1 29.9 15.2 63.2
CONFIDENTIAL DATA: A
SCIG Scenarios Trains Data from T
Prepared for the Port of Los Angeles by Ca
Scenario #2 - Baseline 2010 w. 2035 BNSF volumes

SCIG Yard 0.0 0.0 16.0 0.0 16.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 16.0 0.0 16.0
East L.A. Yard 0.0 0.1 0.2 0.1 0.4 0.0 0.9 1.1 0.2 2.2 0.0 1.2 2.0 0.5 3.7 0.0 2.2 3.3 0.9 6.3
ICTF Yard 0.0 1.5 2.0 1.5 5.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.5 2.0 1.5 5.0
LATC Yard 0.0 0.0 0.0 0.0 0.1 0.0 0.4 0.5 0.1 1.1 0.0 0.4 1.1 0.4 1.9 0.0 0.9 1.7 0.5 3.1

SCIG Yard 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 0.0 0.1 0.1 0.0 0.2 1.6 0.8 0.0 0.0 2.4 0.0 1.6 3.2 0.0 4.8 1.6 2.4 3.3 0.0 7.4
ICTF Yard 0.0 1.1 2.3 0.0 3.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.1 2.3 0.0 3.4
LATC Yard 0.0 0.0 0.0 0.0 0.0 1.3 0.6 0.0 0.0 1.9 0.0 1.3 2.6 0.0 3.8 1.3 1.9 2.6 0.0 5.8

SCIG Yard 0.0 0.0 3.7 0.0 3.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.7 0.0 3.7
East L.A. Yard 0.0 0.1 0.1 0.0 0.2 1.6 0.8 0.0 0.0 2.4 0.0 1.6 3.2 0.0 4.8 1.6 2.4 3.3 0.0 7.4
ICTF Yard 0.0 1.1 2.3 0.0 3.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.1 2.3 0.0 3.4
LATC Yard 0.0 0.0 0.0 0.0 0.0 1.3 0.6 0.0 0.0 1.9 0.0 1.3 2.6 0.0 3.8 1.3 1.9 2.6 0.0 5.8

SCIG Yard 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 0.0 0.1 0.2 0.0 0.3 2.3 1.1 0.0 0.0 3.4 0.0 2.1 4.3 0.0 6.4 2.3 3.3 4.4 0.0 10.0
ICTF Yard 0.0 1.6 3.2 0.0 4.8 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.6 3.2 0.0 4.8
LATC Yard 0.0 0.0 0.0 0.0 0.0 1.8 0.9 0.0 0.0 2.7 0.0 1.7 3.4 0.0 5.1 1.8 2.6 3.4 0.0 7.8

SCIG Yard 0.0 0.0 5.2 0.0 5.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 5.2 0.0 5.2
East L.A. Yard 0.0 0.1 0.2 0.0 0.3 2.3 1.1 0.0 0.0 3.4 0.0 2.1 4.3 0.0 6.4 2.3 3.3 4.4 0.0 10.0
ICTF Yard 0.0 1.6 3.2 0.0 4.8 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.6 3.2 0.0 4.8
LATC Yard 0.0 0.0 0.0 0.0 0.0 1.8 0.9 0.0 0.0 2.7 0.0 1.7 3.4 0.0 5.1 1.8 2.6 3.4 0.0 7.8

SCIG Yard 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 0.0 0.2 0.4 0.0 0.6 3.6 1.8 0.0 0.0 5.4 0.0 3.1 6.3 0.0 9.4 3.6 5.1 6.7 0.0 15.3
ICTF Yard 0.0 3.6 7.3 0.0 10.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.6 7.3 0.0 10.9
LATC Yard 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0

SCIG Yard 0.0 0.0 11.9 0.0 11.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 11.9 0.0 11.9
East L.A. Yard 0.0 0.2 0.4 0.0 0.6 3.6 1.8 0.0 0.0 5.4 0.0 3.1 6.3 0.0 9.4 3.6 5.1 6.7 0.0 15.3
ICTF Yard 0.0 3.6 7.3 0.0 10.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.6 7.3 0.0 10.9
LATC Yard 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0

SCIG Yard 0.0 0.0 16.0 0.0 16.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 16.0 0.0 16.0
East L.A. Yard 0.0 0.1 0.2 0.0 0.3 3.6 1.8 0.0 0.0 5.4 0.0 3.2 6.5 0.0 9.7 3.6 5.1 6.7 0.0 15.4
ICTF Yard 0.0 2.0 4.1 0.0 6.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.0 4.1 0.0 6.1
LATC Yard 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0

SCIG Yard 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 0.0 0.2 0.4 0.0 0.6 3.6 1.8 0.0 0.0 5.4 0.0 3.1 6.3 0.0 9.4 3.6 5.1 6.7 0.0 15.3
ICTF Yard 0.0 3.6 7.3 0.0 10.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.6 7.3 0.0 10.9
LATC Yard 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0

SCIG Yard 0.0 0.0 11.9 0.0 11.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 11.9 0.0 11.9
East L.A. Yard 0.0 0.2 0.4 0.0 0.6 3.6 1.8 0.0 0.0 5.4 0.0 3.1 6.3 0.0 9.4 3.6 5.1 6.7 0.0 15.3
ICTF Yard 0.0 3.6 7.3 0.0 10.9 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 3.6 7.3 0.0 10.9
LATC Yard 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0

SCIG Yard 0.0 0.0 16.0 0.0 16.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 16.0 0.0 16.0
East L.A. Yard 0.0 0.1 0.2 0.0 0.3 3.6 1.8 0.0 0.0 5.4 0.0 3.2 6.5 0.0 9.7 3.6 5.1 6.7 0.0 15.4
ICTF Yard 0.0 2.0 4.1 0.0 6.1 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.0 4.1 0.0 6.1
LATC Yard 0.0 0.0 0.0 0.0 0.0 2.9 1.4 0.0 0.0 4.3 0.0 2.2 4.5 0.0 6.7 2.9 3.6 4.5 0.0 11.0

SCIG Yard 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 0.0 0.1 0.2 0.0 0.2 2.0 1.0 0.0 0.0 3.0 0.0 1.9 3.8 0.0 5.6 2.0 2.9 3.9 0.0 8.8
ICTF Yard 0.0 1.4 2.9 0.0 4.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.4 2.9 0.0 4.3
LATC Yard 0.0 0.0 0.0 0.0 0.0 1.6 0.8 0.0 0.0 2.4 0.0 1.5 3.0 0.0 4.5 1.6 2.3 3.0 0.0 6.9

SCIG Yard 0.0 0.0 4.7 0.0 4.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 4.7 0.0 4.7
East L.A. Yard 0.0 0.1 0.2 0.0 0.2 2.0 1.0 0.0 0.0 3.0 0.0 1.9 3.8 0.0 5.6 2.0 2.9 3.9 0.0 8.8
ICTF Yard 0.0 1.4 2.9 0.0 4.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 1.4 2.9 0.0 4.3
LATC Yard 0.0 0.0 0.0 0.0 0.0 1.6 0.8 0.0 0.0 2.4 0.0 1.5 3.0 0.0 4.5 1.6 2.3 3.0 0.0 6.9

SCIG Yard 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
East L.A. Yard 0.0 0.1 0.3 0.0 0.4 3.2 1.6 0.0 0.0 4.7 0.0 2.8 5.6 0.0 8.4 3.2 4.4 5.9 0.0 13.5
ICTF Yard 0.0 2.6 5.2 0.0 7.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.6 5.2 0.0 7.7
LATC Yard 0.0 0.0 0.0 0.0 0.0 2.5 1.2 0.0 0.0 3.8 0.0 2.2 4.5 0.0 6.7 2.5 3.4 4.5 0.0 10.5

SCIG Yard 0.0 0.0 8.4 0.0 8.4 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 8.4 0.0 8.4
East L.A. Yard 0.0 0.1 0.3 0.0 0.4 3.2 1.6 0.0 0.0 4.7 0.0 2.8 5.6 0.0 8.4 3.2 4.4 5.9 0.0 13.5
ICTF Yard 0.0 2.6 5.2 0.0 7.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 2.6 5.2 0.0 7.7
LATC Yard 0.0 0.0 0.0 0.0 0.0 2.5 1.2 0.0 0.0 3.8 0.0 2.2 4.5 0.0 6.7 2.5 3.4 4.5 0.0 10.5

Final Submitted Comments On Fdeir For BNSF Scig Project 3 6 2012

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Final Submitted Comments On Fdeir For BNSF Scig Project 3 6 2012

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Professor

Mr. Christopher Cannon

Dear Mr. Cannon:

Four of my concerns about the FEIR are:

4) It is unconscionable to claim that the impact of twice as many locomotives to be

Thank you for considering my comments.

Andrea Hricko, MPH

Chris Cannon, Director of Environmental Management

From: "Andrea Hricko" <ahricko@usc.edu>

Chris Cannon, Director of Environmental Management

Good morning Andrea,

Feel free to give me a call if you have any questions.

From: Andrea Hricko [ahricko@usc.edu]

FROM: Gill Hicks

SUBJECT: Transloading estimates

DATE: August 20, 2012

Number of 53-Foot Domestic Rail Containers 641,696 702,703 619,048 654,482

Equivalent Number of TEU by Rail 1,926,069 2,109,184 1,857,948 1,964,400 27%

Equivalent Number of TEU by Truck 911,749 911,749 911,749 911,749 13%

Total Transload Volume 2,837,818 3,020,933 2,769,697 2,876,149 40%

December 4, 2011 (first two pages only)

Problem Statement/Purpose of Study

Step 1: Literature review and evaluation of existing secondary data.

Step 2: Surveys of beneficial cargo owners, logistics service providers, and

Step 3: Surveys of ocean carriers.

Step 5: Draft and final reports

Attachment A: Scope of Work for Starboard Alliance LCC

Attachment B: Scope of Work for Global Business Advocates LLC

Attachment C: Proposed Budget

Attachment D: Summary of TTX Transload Study, 2011

Problem Statement/Purpose of Study

Transloading has important implications for transportation planning in the port

Southern California International Gateway Recirculated Draft EIR September 2012

Scenario #1 - Baseline 2010

Off-Dock Yards Total 912,306 639,251 1,091,004 2,642,561

BNSF Off-Dock Yards Total 448,592 305,116 640,338 1,394,046

UP Off-Dock Yards Total 463,714 334,135 450,666 1,248,515

Total Additional Yard Capacity Needed 0 0 0 0

Scenario #2 - Baseline 2010 w. 2035 BNSF volumes

Off-Dock Yards Total 2,042,661 639,251 1,091,004 3,772,916

BNSF Off-Dock Yards Total 1,578,947 305,116 640,338 2,524,401

UP Off-Dock Yards Total 463,714 334,135 450,666 1,248,515

Total Additional Yard Capacity Needed 0 0 0 0

Scenario #3 - 2016 No Project

Off-Dock Yards Total 685,655 923,450 1,393,227 3,002,332

BNSF Off-Dock Yards Total 342,828 461,725 696,614 1,501,166

UP Off-Dock Yards Total 342,828 461,725 696,614 1,501,166

Total Additional Yard Capacity Needed 0 0 0 0

Scenario #4 - 2016 w. Project

Off-Dock Yards Total 685,655 923,450 1,393,227 3,002,332

BNSF Off-Dock Yards Total 342,828 461,725 696,614 1,501,166

UP Off-Dock Yards Total 342,828 461,725 696,614 1,501,166

Total Additional Yard Capacity Needed 0 0 0 0

Scenario #5 - 2023 No Project

Off-Dock Yards Total 970,087 1,310,802 1,853,554 4,134,443

BNSF Off-Dock Yards Total 485,043 655,401 926,777 2,067,221

UP Off-Dock Yards Total 485,043 655,401 926,777 2,067,221

Total Additional Yard Capacity Needed 0 0 0 0

Scenario #6 - 2023 w. Project

Off-Dock Yards Total 970,087 1,310,802 1,853,554 4,134,443

BNSF Off-Dock Yards Total 485,043 655,401 926,777 2,067,221

UP Off-Dock Yards Total 485,043 655,401 926,777 2,067,221

Total Additional Yard Capacity Needed 0 0 0 0